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Recordkeeping &Reporting
Joe MargetiakCompliance OfficerToledo Area Office
June 2015
RecordkeepingHighlights
Changes to 29 CFR 1904
Effective January 1, 2015
NAICS vs. SIC Codes
• Need to use NAICS from now on– North American Industry Classification System
(NAICS)– Standard Industry Classification (SIC)
• On-line guide available www.OSHA.gov• OSHA 300A forms need NAICS code
Partially Exempt from Recordkeeping
Do not have to keep OSHA 300 and OSHA 300A forms• Employers who have 10 or fewer employees at
all times during the previous calendar year• List of industries with injury rate 75% or less of
3-year average
Industry Examples
• Florists• Shoe Store• Sporting Goods Stores• Colleges• Restaurants• Car Dealers• Doctors
Injury ReportingRequirements
Changes to 29 CFR 1904
Effective January 1, 2015Published September 18, 2014
(proposed rule published June 22, 2011)
Previous Reporting Requirements
• Work-related fatality• Heart attack fatality• Hospitalization of 3 or more employees• Injuries involving a mechanical power press
– 1910.217(g)(1): The employer shall report, within 30 days of the occurrence, all point-of-operation injuries to operators or other employees
Notification requirementsas of January 1, 2015
• Work-related fatality • Work-related in-patient hospitalization • Heart Attack• Work-related amputation• Work-related injury resulting in the loss of an
eye• Mechanical power press point-of-operation
injury
Fatality
• Report within 8 hours of when you find out• If the fatality occurs within 30 days of the
work-related incident• Does not include traffic accidents (except
construction zones) & public transportation• Includes heart attack
Hospitalization
• Report within 24 hours• One or more employees• Admitted for treatment• If hospitalization occurs with 24 hours of incident• Includes heart attack• Observation or testing does not count• Does not include traffic accidents (except
construction zones) & public transportation
Heart Attack
• Heart attack vs. sudden cardiac arrest• Not always instantaneous – symptoms may occur
over a period of time*• May be caused by some work activity that
occurred hours earlier*• Sudden cardiac arrest, such as from an electrical
shock, may appear to be a heart attack*• May or may not be investigated by OSHA• Evaluated on a case-by-case basis
• * Mayo Clinic: Disease and Conditions Heart Attack• http://www.mayoclinic.org/diseases-conditions/heart-attack/basics/symptoms/CON-20019520
Amputation*
• Report within 24 hours• Does not include traffic accidents (except
construction zones) & public transportation• If amputation occurs with 24 hours of incident• Definition of amputation does not include: – avulsion, enucleations (loss of eye), deglovings,
scalpings, severed ears, broken/chipped teeth* as defined in BLS OIIC 2010 manual
Loss of an eye
• Report within 24 hours• If loss occurs with 24 hours of incident• Does not include traffic accidents (except
construction zones) & public transportation(no reference to blindness)
Reporting
• Can not leave a message on an OSHA answering machine/voice mail; no email; no fax
• Options:– Electronic reporting (not yet)
www.osha.gov/report_online
– Call OSHA hotline 800-321-6742– Call local office 419-259-7542 (8:00 - 4:30)